Ii is not just the big transactions that result in OFAC civil penalties for sanctions violations. Pay Pal Inc., the electronic payments processing firm, had a program, for four years, that did not deliver results on scanned payments on a real-time basis, allowing sanctions violations in payments to & from Iran, Cuba, and Sudan. The system was therefore inadequate to block payments. One notorious SDN was specifically identified.
The fine: $7.7m . Any computer program designed catch OFAC-blacklisted individuals and entities must feature instant readouts on the results. What was the company trying to do, save money on the software ? Pay Pal, which provides a valuable service for clients who do not wish a vendor to know their personal financial data, needs to upgrade their compliance to banking best practices, as many NBFIs now do.